United States v. Murillo

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

February 5, 2009

UNITED STATES OF AMERICA, PLAINTIFF,v.MIGUEL DOMINGUEZ MURILLO, DEFENDANT.

The opinion of the court was delivered by: Vaughn R. Walker, Chief Judge, United States District Court

STIPULATION AND [PROPOSED] ORDER RESETTING CHANGE OF PLEA HEARING

IT IS HEREBY STIPULATED between the plaintiff through its attorney, Susan Jerich, Assistant United States Attorney, and defendant Miguel Murillo, through his counsel Ann C. Moorman, Esq. that the date now set for change of plea by defendant Miguel Murillo Sr., to wit, February 5, 2009 shall be vacated and re-set for February 19, 2009. The parties have been diligently negotiating the terms of the plea agreement, however, additional time is needed to resolve certain issues and obtain approval of said plea agreement. The parties further stipulate that time be excluded to and including February 19, 2009 to allow for the effective preparation of counsel as provided by 18 U.S.C. §§3161(h)(1)(F) and 18 U.S.C. §3161(a)(8)(A), The parties also stipulate that the ends of justice would be served by the Court excluding the proposed time period to and including February 19, 2009 pursuant to 18 U.S.C. 3161(h)(8)(A).

IT IS SO STIPULATED:

DATED: February 4, 2009

SUSAN JERICH Assistant United States Attorney

ANN C. MOORMAN Attorney for Defendant Murillo

ORDER

GOOD CAUSE HAVING BEEN SHOWN, it is hereby Ordered that the change of plea hearing in this matter now scheduled for February 5, 2009, shall be vacated and re-set for February 19, 2009 at 2:00 p.m.

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